Submission Number: UBR-DEIS-00221
Received: 12/11/2020 10:12:37 AM
Commenter: M. Scott Newbold
Organization: The Church of Jesus Christ of Latter-Day Saints
Initiative: Uinta Basin Railway EIS
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December 11, 2020
VIA FEDEX AND ELECTRONIC SUBMISSION
Joshua Wayland, PhD
Surface Transportation Board
9300 Lee Highway
Fairfax, VA 22031
Attention: Environmental filing, Docket No. FD 36284
RE: COMMENTS AND OBJECTIONS TO WELLS DRAW ALTERNATIVE DESCRIBED IN DRAFT EIS FOR PROPOSED COMMON-CARRIER RAIL LINE IN DUCHESNE COUNTY, UTAH BEING CONSIDERED BY THE SURFACE TRANSPORTATION BOARD ("STB"); DOCKET NO. FD 36284
Dear Mr. Wayland:
This letter is being sent to you in connection with the proposed common-carrier rail line in Utah and Colorado being proposed by the Seven County Infrastructure Coalition ("Coalition"). The Church of Jesus Christ of Latter-day Saints, a Utah corporation sole, and/or its affiliated entities (collectively, "CHC") own approximately 720 acres ofreal property in Duchesne County, Utah, Tax Parcel Nos. 00-0011-4508 and 00-001-4821, as depicted on Exhibit A enclosed herewith (the "Property"). CHC operates the Timberlane Recreation Camp ("Camp") on the Property, which includes campgrounds and related facilities primarily used by members of The Church of Jesus Christ of Latter-day Saints as part of their youth programs. More information regarding the Camp and current uses of the Property can be found at:
CHC has reviewed the Draft Environmental Impact Statement ("EIS") released on October 30, 2020 by the STB in connection with the proposed rail line project, and other related information on the Uinta Basin Railway's website, and hereby provides its written comments and objections to the Wells Draw Alternative described in the Draft EIS prior to the public comment deadline of December 14, 2020, as set forth herein. As you are aware, the Draft EIS contemplates three (3) proposed routes for the rail line. One route-the Wells Draw Alternative-would cross and impact the Property (the "Wells Draw Alternative"). CHC recognizes that this route is not the route currently preferred by the Coalition or STB, but nevertheless wishes to provide its written comments in the event this route is ultimately selected in the Final EIS.
The northwest quadrant of the Property would be directly impacted by the Wells Draw Alternative, generally depicted on Exhibit A. Following are just some of the impacts to the Property that would occur and for which compensation and/or other accommodations would be needed:
1. Compensation would be needed for the right-of-way area upon which the tracks will be installed;
2. Compensations would be needed for all impacts relating to the "tunnel" that is anticipated and for which additional construction, mining, blasting, and maintenance would be required, and which will create potential hazards, liabilities, and other impacts on the Property;
3. In addition, the proposed rail line would sever the Property into two pieces, creating insufficient access to and limited uses of the severed parcel of the Property. Safe access to the new parcel of the Property will need to be provided over or under the tunnel and/or rail line, for CHC use, including the use of its guests, patrons, and visitors at the Camp; and
4. New fencing and other accommodations would be needed to protect individuals (as well as livestock and wildlife) using the Property from interacting with the rail system.
In addition to the foregoing issues that would be created, CHC also objects to the Wells Draw Alternative being selected as the preferred route in the Final EIS due to other impacts the rail line would have on the Property and its current use. As noted above, the Property is used for the Camp. Visitors and patrons come to the camp in order to enjoy the great outdoors and to reconnect with nature and the earth. Typical activities at the camp include camping, hiking, cooking, nature watching, wilderness survival, devotionals, and other outdoor and religious activities. The proposed rail line on the Property would have negative impacts on these current uses of the Camp and Property. Increased noise, vibration, pollution, and harmful impacts on wildlife and vegetation are all foreseeable effects and justifiable concerns that CHC has in connection with-and that will likely result from-the rail line on the Prope1iy. These impacts would need to be addressed and mitigated. Further, because the Property is used for recreational purposes, including hiking, wandering and recreational vehicle use throughout the Property, there are additional safety and liability concerns that arise for CHC if an active rail line were located on the Property. If the Wells Draw Alternative were selected in the Final EIS by the STB, CHC requests that appropriate mitigation actions be taken by the Coalition in order to alleviate and/or avoid these environmental impacts. Some initial suggested mitigation actions for these issues could include reduced train speeds while on the Property, limited time and date ranges during which trains can pass over the Property, other noise, vibration, and pollution mitigation efforts, and installation of warning signage and safety barriers to prevent pedestrian and vehicular accidents.
For the reasons contained in this letter, CHC encourages STB not to select the Wells Draw Alternative as the preferred route for the rail line in the Final EIS. If this route is selected, CHC respectfully requests that each of the issues described in this letter, as well as any other impacts to the Property caused by this proposed use, be addressed to CHC's satisfaction.
Thank you for your consideration of these concerns and your efforts to protect property owners such as CHC. Please do not hesitate to contact me (email@example.com; 801-240-7415) should you have any questions or need any further information.
The Church of Jesus Christ of Latter-day Saints, a Utah corporation sole
M. Scott Newbold;
Director for Temporal Affairs - Utah Area
[See original attachment for Exhibit A, a map of the Timberlane Recreation Camp and the approximate location of the Wells Draw railway route.]